GitHub makes our anti-bribery commitment clear in a number of company policies.

GitHub's Code of Ethics prohibits employees and contractors from engaging in or contributing to bribery or corruption, and establishes record-keeping requirements:

You must never pay, offer to pay, promise to pay, induce, accept, or authorize payment of anything else of value, to anyone—including to anyone in a position of power or authority, such as government officials, or in commercial transactions—in order to obtain or keep business, or secure any other improper advantage for GitHub or Microsoft. You also must not solicit or accept a bribe, kickback, or any other improper cash payment. ... [GitHub employees] are required to keep accurate and fair records of all transactions involving any expense made on GitHub’s behalf—for example, by keeping receipts and providing accurate descriptions of your expenses—or any other transaction involving the disposal or transfer of GitHub assets. Such actions are required by the U.S. Foreign Corrupt Practices Act, the U.K. Bribery Act of 2010, and anti-bribery laws of other jurisdictions in which GitHub does business and are also simply the right thing to do.

GitHub's Code of Ethics elaborates on certain situations, including gifts, travel, and entertainment; facilitating payments; charitable donations; jobs; and working with representatives, as well as on who is considered a government official.

GitHub's Standards of Conduct prohibit:

Bribing government officials or other individuals to gain an unfair advantage, and taking bribes from anyone.

GitHub’s Gifts and Entertainment Policy explains that bribery is not permitted in connection with travel or entertainment, and provides examples to illustrate improper conduct. The policy describes proper and improper gifts, travel, and entertainment expenses; company processes for gift-giving by GitHub’s directors, officers, employees, and agents and requirements for record-keeping, penalties; and reporting of violations. It includes clear monetary thresholds for gifts along with annual limitations, with limited exceptions for gifts approved by appropriate management. The policy is clear and easily accessible to GitHub employees and contractors.

GitHub employees are required to participate in training on corruption, including bribery. We also provide additional training for particularly relevant people and teams, such as our sales team. The training explains relevant elements of the U.S. Foreign Corrupt Practices Act and the U.K. Bribery Act of 2010. For example,

While the U.S. FCPA is focused on interactions with government officials, the U.K. Bribery Act is broader and extends to bribing anyone, regardless of whether they are a government official. Both laws can extend to GitHub’s actions elsewhere on the globe. GitHub’s policies prohibit bribing anyone, anywhere in the world.